Does UK CBAM apply to my business?

Last verified: 26 October 2026

Author: Oremly

If you import steel, fasteners, aluminium, cement or related goods into the United Kingdom, the first question is simple: does UK CBAM apply to my business? This post gives a plain-English decision test you can run against your import ledger. It is not tax advice. Oremly is software and plain-English guidance for UK CBAM; you file returns yourself through HMRC’s CBAM service via Government Gateway.

UK CBAM is a UK tax on emissions embodied in specified imported goods. Liability starts for goods imported on or after 1 January 2027. It is separate from EU CBAM. An EU tool or EU registration does not cover UK CBAM registration or UK returns. For the law itself, see Finance Act 2026, Part 5 and HMRC's CBAM guidance collection.

The seven-step test

Work through these steps in order. Stop when a step takes you out of scope. If you pass every step and hit the £50,000 threshold, you must register for UK CBAM (on the timetable below).

1. Are the goods imported on or after 1 January 2027?

UK CBAM only applies to qualifying goods imported on or after 1 January 2027. Earlier shipments do not create CBAM liability and do not count towards the registration threshold. If your question is only about 2026 stock, the answer for those consignments is no, but plan now for 2027 arrivals.

2. Are they CBAM goods by commodity code?

Only goods listed in Finance Act 2026, Schedule 16 are in scope: specified aluminium, cement, fertiliser, hydrogen, and iron and steel lines. Schedule 16 lists goods mainly by chapter, 4-digit heading and 6-digit sub-heading, with a few 8-digit codes. Examples relevant to most readers: most of chapter 72 iron and steel, fasteners under heading 7318, aluminium structures and frames under heading 7610, and cement lines under 2523. Match the commodity code on your customs declaration to those Schedule 16 listings. Your declaration will usually show an 8-digit code; use it to see which chapter, heading, sub-heading or code in Schedule 16 it falls under.

Check the named exceptions too: ferrous scrap (heading 7204), several ferro-alloys and some fertilisers are excepted, while aluminium scrap (7602) is simply not listed, so it is out of scope for that reason. Check your codes against the list in Finance Act 2026, Schedule 16.

3. Are you the importer?

The liable person is the importer: usually the person named on the customs declaration where import duty is payable, or the person on whose behalf goods are imported where no duty is due. If a customs broker or forwarder lodges the declaration for you, they do not become the importer for CBAM. A tax agent may later submit returns but cannot register and takes no CBAM liability.

4. Is the import in the course of a business?

CBAM charge and registration concern imports in the course of a business. Private or non-commercial imports are out. If you are a steel stockholder, fastener wholesaler, builders’ merchant or aluminium fabricator buying for stock or fabrication, this step is usually yes.

5. Do any statutory exclusions apply?

Even for business imports of Schedule 16 goods, some consignments attract no CBAM charge and generally do not count towards the £50,000 threshold:

UK place of origin under the non-preferential rules
Returned goods relief cases (and certain Northern Ireland return-in-the-same-state scenarios described in HMRC guidance)
Temporary admission with full customs-duty relief

Temporary admission with only partial or no relief can still be in scope. Special-procedure rules are detailed; if goods sit under a special procedure, check HMRC’s guidance before treating them as out of the threshold. If your case is not covered, you can ask HMRC: general questions go through an online form, detailed policy questions go to cbampolicyteam@hmrc.gov.uk, and HMRC says it will "usually send you a reply by email within 15 days".

6. Does your customs value hit £50,000 under either test?

Registration is triggered if either test is met:

Forward test: on any day from 1 January 2027, you expect to import in-scope CBAM goods with aggregate value of £50,000 or more within the next 30 days. If that expectation is met, you become liable to register on that day; or
Backward test: Finance Act 2026, Schedule 17 (paragraph 2(2)(a)) applies this test when "it is the first day of the month": did CBAM goods imported in the preceding 12 months total £50,000 or more? For 2027, look back only to 1 January 2027. Pre-2027 imports do not count. HMRC’s guidance on working out your registration date says that if this check is met, "you may be liable to register for CBAM from the date your imports met the £50,000 registration threshold". That date can fall before the first of the month, so plan from it.

If both tests are met, HMRC says to "use the earliest date on which you become liable for CBAM as your registration start date". Value means the customs value used (or that would be used) for import duty, not emissions, and not the tax itself. You can run a rough check with the CBAM threshold checker.

7. What is your registration deadline?

Ordinarily you must register within 30 days of the day registration is first triggered. If you first trigger in 2027, the transitory rules require registration by 31 January 2028 instead. GOV.UK says registration will open on 1 January 2028; until then, keep the records the law already requires (commodity code, description, import date, value and weight).

Illustrative example: crossing £50,000 on customs value

Illustrative. Figures are fictional. Basis: three business imports of Schedule 16 goods into Great Britain after 1 January 2027 by the named importer; UK origin and returned-goods relief do not apply; values are the customs values that would be used for import duty. No CBAM rates or default emissions values are used. Those figures are not yet final.

Date (2027)	Goods (example listing)	Customs value	Running cumulative
12 February	Steel plate (Ch. 72)	£18,000	£18,000
3 March	Hex bolts (7318)	£16,500	£34,500
20 March	Aluminium window frames (7610)	£15,500	£50,000
Total	Three consignments	£50,000	£50,000

What triggers (and what does not):

Forward test: no day has an expected (or actual) £50,000 within the next 30 days. The highest 30-day window total is £34,500 (12 February plus 3 March). The 20 March line sits outside that window, so the forward test does not trigger.
Backward test: the monthly check on 1 March 2027 finds only £18,000 since 1 January 2027. The monthly check on 1 April 2027 finds £50,000 (imports from 1 January to 31 March 2027), so the test is met that day. Under HMRC’s registration-date guidance, you may be liable to register from 20 March 2027, the date your imports met the £50,000 registration threshold. Plan from 20 March 2027, the earlier of the two dates.

For a 2027 trigger, register by 31 January 2028. This illustration does not estimate tax due.

What registration means next (signpost only)

Once you are registrable or registered, you must account for the tax, keep records for six years (HMRC counts the six years from the later of the date a record was created and the end of the accounting period it relates to), and file returns. The first accounting period is calendar year 2027, with return and payment due 31 May 2028 under the transitory timetable. Default emissions values and CBAM rates for calculating the tax are not yet final. The government published draft default values on 16 October 2026; the notice has no force of law until 1 January 2027. HMRC published illustrative rates on the same day (for example £9.69 per tCO2e for iron and steel), which it says are not forecasts. The first real rates, for January to March 2027, are due before the end of 2026, and after that HMRC will publish each quarter’s rates by the start of the quarter. The list of qualifying carbon pricing schemes for carbon price relief is not exhaustive and will be updated, according to HMRC.

Your customs broker can lodge declarations and may help with paperwork, but they are not the liable person if they declare for you, and they cannot register for you. Oremly helps UK importers read the import ledger, chase supplier emissions data, calculate liability, store evidence and prepare a return-ready summary. It does not file the return. You file through HMRC. Broker workspace: register your interest.

Sources

Primary sources checked on 26 October 2026:

Finance Act 2026, Part 5 (charge, importer, exemptions, commencement)
Finance Act 2026, Schedule 16 (CBAM goods)
Finance Act 2026, Schedule 17 (registration threshold and administration)
S.I. 2026/802 (value, records)
S.I. 2026/830 (2027 registration and return deadlines)
CBAM policy summary (updated 16 October 2026)
Check if you’ll need to register for CBAM (registration will open on 1 January 2028)
The CBAM (Default Values) Force of Law Notice (Draft) (16 October 2026)
Illustrative CBAM rates and worked example (16 October 2026)
Check if you’re the importer (16 July 2026)
Work out the date you’ll need to register (16 July 2026)
Goods that may not contribute to the registration threshold (16 July 2026)
Qualifying carbon pricing schemes (published 27 August 2026)
Keeping records for CBAM (updated 16 October 2026; six-year record period)
Send HMRC questions about CBAM (published 20 October 2026, updated 21 October 2026)

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Does UK CBAM apply to my business? A plain-English test